On Point: 40. TPRs

Barron County v. K.L.P., 2026AP460 & 2026AP461, 7/21/26, District III (ineligible for publication); case activity

The COA held that the circuit court did not lose competency to enter disposition orders in an action to terminate parental rights if it accepts a no-contest plea to the grounds for termination without hearing testimony, even if Wis. Stat. § 48.422(3) requires testimony.

Waupaca County Department of Health & Human Services v. J.L.C. and M.M.C., 2026AP498 and 647, 6/25/26, District IV (ineligible for publication); case activity

JLC and MMC each appeal the circuit court order terminating their parental rights to their child, CMC, arguing that the court erred in granting Waupaca County’s motion for summary judgment on grounds. COA concludes that the ground on which SJ was granted, continuing denial of visitation, requires the county to prove that the parents received adequate notice of the conditions of resuming visitation, and the county cannot make this showing under the facts. Therefore, COA reverses the order and remands with directions that the circuit court grant partial summary judgment to both parents on the continuing denial of visitation ground. 

Green County v. K.M.S., 2025AP199, 6/18/26, District IV (ineligible for publication); case activity

Applying an exceptionally deferential review to K.M.S.’s ineffectiveness claims, COA affirms in the face of a somewhat confusing appellate record.

Waupaca County Department of Health & Human Services v. C.J.T., 2026AP794, 6/11/26, District IV (ineligible for publication); case activity

CJT appeals the circuit court order terminating his parental rights to his son, JJT, arguing that the court failed to demonstrate that it considered all of the required factors at disposition. Despite the deferential standard of review to a TPR dispositional order, COA agrees, reversing the termination order and remanding for a proper exercise of discretion.

State v. M.G., 2025AP2883-2888, 5/15/26, District I (ineligible for publication); case activity

M.G. appeals orders terminating her parental rights to her six children on the basis that the circuit court erred when it found that the state had proven by clear and convincing evidence that child protective services made reasonable efforts and she failed to assume parental responsibility for the three youngest children. COA affirms.

State v. J.G., III, 2025AP469-474, 5/15/26, District I (ineligible for publication); case activity

Although J.G. levies a number of appellate attacks, COA finds his arguments uniformly unavailing and affirms.

Marquette Department of Human Services v. B.L.J., 2026AP400-402, 5/7/26, District IV (ineligible for publication); case activity

In yet another decision applying the deferential standard of review to a TPR dispositional order, COA rejects the appellant’s arguments which ignore that standard of review.

Brown County Health &Human Services v. J.L., 2026AP176, 5/1/26, District III (ineligible for publication); case activity

“Julie” challenges the circuit court’s exercise of discretion at disposition as to two factors of consideration. However, the deferential standard of review applicable to dispositional decisions results in affirmance.

Monroe County Department of Human Services v. A.S., 2026AP65-66, 4/23/26, District I (ineligible for publication); case activity

Although A.S. raises multiple challenges to this TPR, COA uniformly finds her arguments unavailing.

State v. D.H., 2025AP2668, 4/10/26, District I (ineligible for publication); case activity

Potentially reviving an issue many may have thought already settled, COA upholds the circuit court’s order for plea withdrawal in a case involving a deficient colloquy regarding the dispositional burden of proof in a TPR case.